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Applications of AT&T Mobility Spectrum LLC and Qualcomm Incorporated For Consent To Assign or Transfer Control of Lower 700 MHz Band Licenses

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Released: June 10, 2011

Federal Communications Commission

DA 11-1044

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of
)
)

Applications of AT&T Mobility Spectrum LLC
) WT Docket No. 11-18
and Qualcomm Incorporated
)
)

For Consent To Assign or Transfer Control of
)
Lower 700 MHz Band Licenses
)

SECOND PROTECTIVE ORDER

Adopted: June 10, 2011


Released: June 10, 2011

By the Chief, Wireless Telecommunications Bureau:
1. In this Second Protective Order, we adopt procedures to provide more limited access to
certain especially competitively sensitive information that may be filed in this proceeding, which, if
released to competitors or those with whom the Submitting Party does business, would allow those
persons to gain a significant advantage in the marketplace or in negotiations. We anticipate that such
materials will be necessary to develop a more complete record on which to base the Commission's
decision. While we are mindful of the highly sensitive nature of such information, we are also mindful of
the right of the public to participate in this proceeding in a meaningful way. Therefore, consistent with
past practice,1 we will make such information available to participants in this proceeding, but limit such
access to their Outside Counsel of Record, their Outside Consultants and experts whom they retain to
assist them in this proceeding, and their Outside Counsel's and Outside Consultants' employees. We
conclude that the procedures we adopt in this Second Protective Order give appropriate access to the
public while protecting especially competitively sensitive information from improper disclosure, and that
the procedures thereby serve the public interest.2
2. Definitions. As used herein, capitalized terms not otherwise defined in this Second Protective
Order shall have the following meanings:
"Acknowledgment" means the Acknowledgment of Confidentiality attached as Appendix B
hereto.


1 See, e.g., Applications of Comcast Corporation, General Electric Company and NBC Universal, Inc. For Consent
to Assign Licenses or Transfer Control of Licensees,
MB Docket 10-56, Second Protective Order, 25 FCC Rcd 2140
(MB 2010); Applications of AT&T Inc. and Centennial Communications Corp. For Authority to Transfer Control,
WT Docket No. 08-246, Second Protective Order, 24 FCC Rcd 7182 (WTB 2009); Application of News
Corporation and The DIRECTV Group, Inc., Transferors, and Liberty Media Corporation, Transferee, for Authority
to Transfer Control,
MB Docket 07-18, Protective Order, 22 FCC Rcd 12797 (MB 2007) (adopting a second
protective order); News Corporation, General Motors Corporation, and Hughes Electronic Corporation, MB
Docket No. 03-124, Order, 18 FCC Rcd 15198 (MB 2003) (adopting a second protective order).
2 This Second Protective Order does not constitute a resolution of the merits concerning whether any information
submitted under the Second Protective Order would be released publicly by the Commission upon a proper request
under the Freedom of Information Act (FOIA) or otherwise.

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DA 11-1044

"Competitive Decision-Making" means that a person's activities, association, or relationship with
any of its clients involve advice about or participation in the relevant business decisions or the analysis
underlying the relevant business decisions of the client in competition with or in a business relationship
with the Submitting Party.
"Highly Confidential Information" means information that is not otherwise available from
publicly available sources; that the Submitting Party has kept strictly confidential; that is subject to
protection under FOIA and the Commission's implementing rules; that the Submitting Party claims
constitutes some of its most sensitive business data which, if released to competitors or those with whom
the Submitting Party does business, would allow those persons to gain a significant advantage in the
marketplace or in negotiations; and that it is described in Appendix A to this Second Protective Order, as
the same may be amended from time to time.
"Outside Counsel of Record" or "Outside Counsel" means the attorney(s), firm(s) of attorneys, or
sole practitioner(s), as the case may be, retained by a party in this proceeding, provided that such
attorneys are not involved in Competitive Decision-Making. The term "Outside Counsel of Record"
includes any attorney representing a non-commercial party in this proceeding, provided that such attorney
is not involved in Competitive Decision-Making.
"Outside Consultant" means a consultant or expert retained for the purpose of assisting Outside
Counsel or a party in this proceeding, provided that such consultant or expert is not involved in
Competitive Decision-Making. The term "Outside Consultant" includes any consultant or expert
employed by a non-commercial party in this proceeding, provided that such consultant or expert is not
involved in Competitive Decision-Making.
"Redacted Highly Confidential Document" means a copy of a Stamped Highly Confidential
Document where the Highly Confidential Information has been redacted.
"Reviewing Party" means a person who has obtained access to Highly Confidential Information
(including Stamped Highly Confidential Documents) pursuant to paragraphs 6 or 10 of this Second
Protective Order.
"Stamped Highly Confidential Document" means any document, or any part thereof, that contains
Highly Confidential Information and that bears the legend (or which otherwise shall have had the legend
recorded upon it in a way that brings its attention to a reasonable examiner) "HIGHLY CONFIDENTIAL
INFORMATION SUBJECT TO SECOND PROTECTIVE ORDER IN WT DOCKET NO. 11-18
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION," unless the Commission determines,
sua sponte or by request pursuant to sections 0.459 or 0.461 of its rules, that any such document is not
entitled to highly confidential or confidential treatment. The term "document" means any written,
recorded, electronically stored, or graphic material, whether produced or created by the Submitting Party
or another person. By designating a document a "Stamped Highly Confidential Document," a Submitting
Party signifies and represents that it contains Highly Confidential Information.
"Submitting Party" means a person who submits a Stamped Highly Confidential Document.
3. Designation of Information as Highly Confidential. Only that information described in
Appendix A to this Second Protective Order may be designated by a Submitting Party as Highly
Confidential. To the extent that a Submitting Party believes that future submissions contain information
that should be designated as Highly Confidential, the Submitting Party must file a request to designate the
information as Highly Confidential along with a supporting explanation. If the request is granted, in
whole or in part, an amended Appendix A will be issued, and the Submitting Party may designate as
Highly Confidential Information only that information and those documents specifically described in the
amended Appendix A.
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4. Submission of Stamped Highly Confidential Documents. A Submitting Party shall submit to
the Secretary's Office one copy of each Stamped Highly Confidential Document it wishes to file, two
copies of the Redacted Highly Confidential Document in redacted form and an accompanying cover
letter. Each page of the Stamped Highly Confidential Document shall be stamped "HIGHLY
CONFIDENTIAL INFORMATION SUBJECT TO SECOND PROTECTIVE ORDER IN WT
DOCKET NO. 11-18 BEFORE THE FEDERAL COMMUNICATIONS COMMISSION." The cover
letter also shall contain this legend. Each Redacted Highly Confidential Document shall have the same
pagination as the Stamped Highly Confidential Document from which it is derived. The two copies of the
Redacted Highly Confidential Document and the accompanying cover letter shall be stamped
"REDACTED FOR PUBLIC INSPECTION." To the extent that any page of the filing contains both
Highly Confidential Information or Confidential Information and non-confidential information, only the
Highly Confidential Information and Confidential Information may be redacted and the page of the
unredacted filing shall clearly distinguish among the Highly Confidential Information, the Confidential
Information, and the non-confidential information. In addition, two copies of each Stamped Highly
Confidential Document and the accompanying cover letter must be delivered in person to Kathy Harris,
Mobility Division, Wireless Telecommunications Bureau, Federal Communications Commission, 445
12th Street, S.W., Room 6329, Washington, D.C. 20554.
5. Copying Sensitive Documents. If, in the reasonable judgment of the Submitting Party, a
document contains information so sensitive that copying of it should be restricted, the Submitting Party
may mark the document with the legend "Additional Copying Prohibited." A Reviewing Party shall
receive only one copy of the document and no further copies of such document, in any form, shall be
made, subject to the provisions for access to information in electronic format in paragraph 8. Application
for relief from this restriction against further copying may be made to the Commission, with notice to
Counsel of Record for the Submitting Party.
6. Procedure for Obtaining Access to Stamped Highly Confidential Documents. Any person
seeking access to Stamped Highly Confidential Documents and Highly Confidential Information subject
to this Second Protective Order shall sign and date the Acknowledgment agreeing to be bound by the
terms and conditions of this Second Protective Order; and file the Acknowledgment with the Bureau, on
behalf of the Commission. Such person shall also serve a copy of the Acknowledgment upon each
Submitting Party through its Outside Counsel of Record so that it is received at least five business days
prior to such person's reviewing or having access to the Submitting Party's Stamped Highly Confidential
Documents or Highly Confidential Information, except that, where the person seeking access is one
described in either clause 1 or 2 of paragraph 10, the Acknowledgment shall be delivered promptly prior
to the person's obtaining access. Each Submitting Party shall have an opportunity to object to the
disclosure of its Stamped Highly Confidential Documents or Highly Confidential Information to any such
person. A Submitting Party must file any such objection at the Commission and serve it on Counsel
representing, retaining or employing such person within three business days after receiving a copy of that
person's Acknowledgment (or where the person seeking access is one described in clause 1 or 2 of
paragraph 10, file and serve such objection as promptly as practicable after receipt of the
Acknowledgment). Until any such objection is resolved by the Commission and, if appropriate, by any
court of competent jurisdiction, and unless such objection is resolved in favor of the person seeking
access, a person subject to an objection from a Submitting Party shall not have access to Stamped Highly
Confidential Documents or Highly Confidential Information.
7. Review of Stamped Highly Confidential Documents. A Submitting Party shall make available
for review the Stamped Highly Confidential Documents of such party at the offices of the party's Outside
Counsel of Record. A Reviewing Party shall be provided the following alternatives, subject to the terms
of paragraph 5: (1) a Reviewing Party will be provided adequate opportunity to inspect the documents on
site; (2) a Reviewing Party may inspect the documents on site with the ability to request copies, at cost, of
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DA 11-1044

all or some of the documents; or (3) a Reviewing Party may request a complete set of the documents at
cost, allowing two business days after the request is made for receipt of the copies. If a Reviewing Party
plans on requesting a complete set of documents, it is encouraged to make such a request at the time it
submits the Acknowledgment to allow it the opportunity to begin reviewing the documents at the end of
the five-day period referred to in paragraph 6. All copies of documents that are removed from the
Submitting Party's office must be returned or destroyed in accordance with the terms of paragraph 19.
8. Review of Highly Confidential Information in Electronic Format. A Submitting Party shall
make available to a Reviewing Party one copy of Highly Confidential Information contained, recorded, or
electronically stored on a CD-ROM, DVD, flash drive, portable hard drive or similar electronic storage
device, which shall be considered a Stamped Confidential Document. The disk or other medium
containing the information in electronic format should be physically sent to the Reviewing Party; a
Reviewing Party may not require that it be transmitted electronically. A Reviewing Party may
temporarily load onto a computer the information in electronic format. Once loaded onto a computer, any
files containing Highly Confidential Information shall be password protected immediately. The Highly
Confidential Information may not be stored on a computer after being analyzed. After the analysis is
complete, the results of such analysis may be stored by saving the results (but not the original underlying
Highly Confidential Information) to a mobile data storage medium, which, if it contains Highly
Confidential Information, shall be treated as a Stamped Highly Confidential Document and so marked.
All files containing Highly Confidential Information shall be deleted from the computer as soon as
practicable. The original disk or other storage medium shall be stored securely and a record kept of any
persons given access to it.
9. Use of Highly Confidential Information. Persons obtaining access to Highly Confidential
Information (including Stamped Highly Confidential Documents) under this Second Protective Order
shall use the information solely for the preparation and conduct of this proceeding before the Commission
and any subsequent judicial proceeding arising directly from this proceeding and, except as provided
herein, shall not use such documents or information for any other purpose, including without limitation
business, governmental, or commercial purposes, or in other administrative, regulatory or judicial
proceedings. Should the Commission rely upon or otherwise make reference to the contents of any of the
Stamped Highly Confidential Documents or Highly Confidential Information in its decision in this
proceeding, it will do so by redacting any Highly Confidential Information from the public version of the
decision and by making the unredacted version of the decision available only to a court and to those
persons entitled to access to Highly Confidential Information under this Second Protective Order.
10. Permissible Disclosure. A Reviewing Party may discuss and share the contents of the
Stamped Highly Confidential Documents and Highly Confidential Information with another Reviewing
Party and with the Commission and its staff. A Submitting Party's Stamped Highly Confidential
Documents and Highly Confidential Information may also be disclosed to employees and Counsel of the
Submitting Party. Subject to the requirements of paragraph 6, a Reviewing Party may disclose Stamped
Highly Confidential Documents and Highly Confidential Information to: (1) paralegals or other
employees of such Reviewing Party assisting them in this proceeding; and (2) employees of third-party
contractors involved solely in one or more aspects of organizing, filing, coding, converting, storing, or
retrieving documents or data or designing programs for handling data connected with this proceeding, or
performing other clerical or ministerial functions with regard to documents connected with this
proceeding.
11. Filings with the Commission. A Reviewing Party or a Submitting Party may in any document
that it files in this proceeding disclose Highly Confidential Information only if it complies with the
following procedure. The party shall submit to the Secretary's Office one copy of the filing containing
Highly Confidential Information (the "Highly Confidential Filing"), two copies of the filing in redacted
form, i.e., containing no Highly Confidential Information (the "Redacted Highly Confidential Filing"),
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and an accompanying cover letter. The cover or first page of the Highly Confidential Filing and each
page of the Highly Confidential Filing that contains or discloses Highly Confidential Information must be
clearly marked "HIGHLY CONFIDENTIAL INFORMATION SUBJECT TO SECOND
PROTECTIVE ORDER IN WT DOCKET NO. 11-18 before the Federal Communications Commission."
The cover letter shall also contain this legend. The Highly Confidential Filing shall be made under seal,
and will not be placed in the Commission's public file. The two copies of the Redacted Highly
Confidential Filing and the accompanying cover letter shall be stamped "REDACTED FOR PUBLIC
INSPECTION." The cover letter accompanying the Redacted Highly Confidential Filing shall state that
the party is filing a redacted version of the filing. Each Redacted Highly Confidential Filing shall have
the same pagination as the Highly Confidential Filing from which it is derived. To the extent that any
page of the Highly Confidential Filing contains any type of Confidential Information, only the
Confidential Information (of whatever type) may be redacted and the page of the unredacted Confidential
Filing shall clearly distinguish among the various types of Confidential Information and the non-
confidential information. Two copies of each Highly Confidential Filing and the accompanying cover
letter must be delivered in person to Kathy Harris, Mobility Division, Wireless Telecommunications
Bureau, Federal Communications Commission, 445 12th Street, S.W., Room 6329, Washington, D.C.
20554, and one copy must be served on the relevant Submitting Party. Parties should not provide
courtesy copies of pleadings containing Highly Confidential Information to Commission staff unless the
Bureau so requests, and any such courtesy copies shall be submitted under seal.
12. Non-Disclosure of Stamped Highly Confidential Documents and Highly Confidential
Information. Except with the prior written consent of the Submitting Party or as provided under this
Second Protective Order, neither a Stamped Highly Confidential Document nor any Highly Confidential
Information may be disclosed further.
13. Protection of Stamped Highly Confidential Documents and Highly Confidential Information.
A Reviewing Party shall have the obligation to ensure that access to Stamped Highly Confidential
Documents and Highly Confidential Information is strictly limited as prescribed in this Second Protective
Order. A Reviewing Party shall further have the obligation to ensure that Stamped Highly Confidential
Documents and Highly Confidential Information are used only as provided in this Second Protective
Order.
14. Requests for Additional Disclosure. If any person requests disclosure of Highly Confidential
Information outside the terms of this Second Protective Order, such a request will be treated in
accordance with sections 0.442 and 0.461 of the Commission's rules.
15. Client Consultation. Nothing in this Second Protective Order shall prevent or otherwise
restrict Outside Counsel from rendering advice to their clients relating to the conduct of this proceeding
and any subsequent judicial proceeding arising therefrom and, in the course thereof, relying generally on
examination of Stamped Highly Confidential Documents or Highly Confidential Information; provided,
however
, that in rendering such advice and otherwise communicating with such client, Outside Counsel
shall not disclose Stamped Highly Confidential Documents or Highly Confidential Information.
16. No Waiver of Confidentiality. Disclosure of Highly Confidential Information as provided
herein by any person shall not be deemed a waiver by any Submitting Party of any privilege or
entitlement to confidential treatment of such Highly Confidential Information. Reviewing Parties, by
viewing this material, agree: (1) not to assert any such waiver; (2) not to use Highly Confidential
Information to seek disclosure in any other proceeding; and (3) that accidental disclosure of Highly
Confidential Information by a Submitting Party shall not be deemed a waiver of any privilege or
entitlement as long as the Submitting Party takes prompt remedial action.
17. Subpoena by Courts, Departments, or Agencies. If a court, or a federal or state department or
agency issues a subpoena for or orders the production of Stamped Highly Confidential Documents or
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Highly Confidential Information that a party has obtained under terms of this Second Protective Order,
such party shall promptly notify each Submitting Party of the pendency of such subpoena or order.
Consistent with the independent authority of any court, department or agency, such notification must be
accomplished such that the Submitting Party has a full opportunity to oppose such production prior to the
production or disclosure of any Stamped Highly Confidential Document or Highly Confidential
Information.
18. Violations of Second Protective Order. Should a Reviewing Party violate any of the terms of
this Second Protective Order, such Reviewing Party shall immediately convey that fact to the
Commission and to the Submitting Party. Further, should such violation consist of improper disclosure of
Highly Confidential Information, the violating person shall take all necessary steps to remedy the
improper disclosure. The Commission retains its full authority to fashion appropriate sanctions for
violations of this Second Protective Order, including but not limited to suspension or disbarment of
Outside Counsel or Consultants from practice before the Commission, forfeitures, cease and desist orders,
and denial of further access to Highly Confidential Information in this or any other Commission
proceeding. Nothing in this Second Protective Order shall limit any other rights and remedies available to
the Submitting Party at law or in equity against any person using Highly Confidential Information in a
manner not authorized by this Second Protective Order.
19. Termination of Proceeding. The provisions of this Second Protective Order shall not
terminate at the conclusion of this proceeding. Within two weeks after conclusion of this proceeding and
any administrative or judicial review, Reviewing Parties shall destroy or return to the Submitting Party
Stamped Highly Confidential Documents and all copies of the same. No material whatsoever derived
from Stamped Highly Confidential Documents may be retained by any person having access thereto,
except Outside Counsel may retain, under the continuing strictures of this Second Protective Order, two
copies of pleadings (one of which may be in electronic format) prepared in whole or in part by that party
that contain Highly Confidential Information, and one copy of orders issued by the Commission or
Bureau that contain Highly Confidential Information. All Outside Counsel shall certify compliance with
these terms and shall deliver such certification to Outside Counsel for the Submitting Party not more than
three weeks after conclusion of this proceeding. The provisions of this paragraph regarding retention of
Stamped Highly Confidential Documents and copies of the same and Highly Confidential Information
shall not be construed to apply to the Commission or its staff.
20. Authority. This Order is issued pursuant to sections 4(i), 214 and 310(d) of the
Communications Act of 1934, as amended, 47 U.S.C. 154(i), 214 and 310(d), Section 4 of the
Freedom of Information Act, 5 U.S.C. 552(b)(4), and authority delegated under section 0.291 of the
Commission's rules, 47 C.F.R. 0.291, and is effective upon its adoption.
FEDERAL COMMUNICATIONS COMMISSION
Ruth Milkman
Chief, Wireless Telecommunications Bureau
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APPENDIX A

Highly Confidential Information and Documents

As specified in paragraphs 2 and 3 of the Second Protective Order, only information and
documents set forth in this Appendix A and that otherwise meet the definition of Highly Confidential
Information or Highly Confidential Documents may be designated as Highly Confidential. This
Appendix will be updated as necessary.
With respect to each of AT&T's and Qualcomm's requests to the Commission for protection
of confidential information under a Second Protective Order, dated June 7, 2011, the following types
of information:
A.
Detailed strategic or business planning documents discussing plans for future marketing,
sales, distribution, deployment, technology, capacity, competition, and/or staffing
strategies.
AT&T's response to the General Information Request Regarding the AT&T/Qualcomm
Transaction, WT Docket No. 11-18, May 20, 2011 ("AT&T GIR") numbers 2.i.(a), (d)-(g),
(h).2; 2.ii.(i) (with respect to details regarding future plans to deploy a wireless technology
format), (j), (k)(iv)-(vi); 3.i; 5; 7; 9; 11; 19.ii; 20-22; 23 (other than public documents); 24;
25; and 26 may include information that falls within this category of documents and
information that is eligible for Highly Confidential Treatment.
Qualcomm's response to the General Information Request Regarding the
AT&T/Qualcomm Transaction, WT Docket No. 11-18, May 20, 2011 ("Qualcomm GIR")
numbers: 2; 3; 6-8; and 10 may include information that falls within this category of
documents and information that is eligible for Highly Confidential Treatment.
B.
Detailed or granular engineering, technical or pricing data including engineering capacity
information, testing information, capabilities/characteristic/ performance information,
pricing, or future capacity information or information about specific facilities or plans for
expansion, enhancement or construction of new facilities, including collocation sites, cell
sites, maps of network facilities, or information about the backhaul provider to a site and
competitive strategies.
AT&T's response to AT&T GIR numbers 3.i; 7; 19.ii; 20; and 26 may include information
that falls within this category of documents and information that is eligible for Highly
Confidential Treatment.
Qualcomm's response to Qualcomm GIR numbers 2; 3; 6-8; and 10 may include
information that falls within this category of documents and information that is eligible for
Highly Confidential Treatment.
C.
Current and forecasted churn or customer change information/data that details the number
or anticipated changes in the number of customers or amount of traffic and why, including
churn rate data broken down by zip code or other granular level.
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AT&T's response to AT&T GIR numbers 3.i, iii; 4; 25; and 26 may include information
that falls within this category of documents and information that is eligible for Highly
Confidential Treatment.
Qualcomm's response to Qualcomm GIR numbers 2; 3; 6-8; and 10 may include
information that falls within this category of documents and information that is eligible for
Highly Confidential Treatment.
D.
Granular or detailed valuation or financial analysis information including operational costs,
market share, marginal revenue and firm-specific price elasticities.
AT&T's response to AT&T GIR numbers 11; 20; and 26 may include information that falls
within this category of documents and information that is eligible for Highly Confidential
Treatment.
Qualcomm's response to Qualcomm GIR numbers 2-10 may include information that falls
within this category of documents and information that is eligible for Highly Confidential
Treatment.
E.
Detailed information describing or illustrating how a Submitting Party analyzes its
competitors, including sources and methods used in these analyses, any limits on use of
these analyses or data, and how such analyses or data are used.
AT&T's response to AT&T GIR numbers 15; 17.ii, iii; 20; and 26 may include information
that falls within this category of documents and information that is eligible for Highly
Confidential Treatment.
F.
Information or documents that identify third parties with whom a company is negotiating
prices for and values of products, services and/or assets; and/or the terms being negotiated.
Qualcomm's response to Qualcomm GIR numbers: 2-4; and 6-10 may include information
that falls within this category of documents and information that is eligible for Highly
Confidential Treatment.
G.
Information or documents discussing research, development, innovation and/or expansion
including trade secrets, patents, or other intellectual property rights and new products or
facilities.
AT&T's response to AT&T GIR numbers 3.i.; 7; and 20 may include information that falls
within this category of documents and information that is eligible for Highly Confidential
Treatment.
Qualcomm's response to Qualcomm GIR numbers 2; 3; 6-8; and 10 may include
information that falls within this category of documents and information that is eligible for
Highly Confidential Treatment.
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APPENDIX B

Acknowledgment of Confidentiality

WT Docket No. 11-18

I hereby acknowledge that I have received and read a copy of the foregoing Second Protective
Order in the above-captioned proceeding, and I understand it.
I agree that I am bound by the Second Protective Order and that I shall not disclose or use
Stamped Highly Confidential Documents or Highly Confidential Information except as allowed by the
Second Protective Order.
I acknowledge that a violation of the Second Protective Order is a violation of an order of the
Federal Communications Commission.
I certify that I am not involved in Competitive Decision-Making.
Without limiting the foregoing, to the extent that I have any employment, affiliation, or role with
any person or entity other than a conventional private law firm (such as, but not limited to, a lobbying or
advocacy organization), I acknowledge specifically that my access to any information obtained as a result
of the Second Protective Order is due solely to my capacity as Counsel or Outside Consultant to a party or
as a person described in paragraph 10 of the foregoing Second Protective Order and agree that I will not
use such information in any other capacity.
I acknowledge that it is my obligation to ensure that Stamped Highly Confidential Documents are
not duplicated except as specifically permitted by the terms of the Second Protective Order.
I certify that I have verified that there are in place procedures at my firm or office to prevent
unauthorized disclosure of Stamped Highly Confidential Documents and Highly Confidential
Information.
Capitalized terms used herein and not otherwise defined shall have the meanings ascribed to them
in the Protective Order or the Second Protective Order.
Executed this ___ day of _____________, 2011.

_________________________________

[Name]

[Position]

[Address]
[Telephone]
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